Middle Office for Top 5 Bank Resolves Consent Order Issues

One of the nation’s top 5 banks received a consent order from the United States Office of the Comptroller of the Currency (OCC) requiring them to improve their Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program. As the bank began remediation of over 300,000 customers, they wanted to develop, communicate, and implement standard processes. Each of their 23 Lines of Business (LOB) had slightly different business models, systems, vendor teams, and organizational structures, which made standardization difficult. In addition, the large size of the project made internal communication a challenge. They needed to create a centralized middle office to serve as an intermediary to help solve these issues.

Results

The bank established and maintained a customer due diligence program up to regulatory standards to fulfill the consent order. Additionally, the Middle Office helped the bank more efficiently remediate the required customers, resolving over 3,500 issues and processing over 18,500 special cases, through:

Centralized issue management

Increased awareness of remediation risks and issues, which allowed for more informed decisions

LOB awareness of program directives, which aided in implementation

Standardized execution across the program, which increased operational throughput

3,500

Issues Resolved

18,500

Special Cases Processed

Finding the Middle

The Middle Office sits between the remediation team, the LOBs, and the vendors to centralize processes, bridge gaps in communication, and identify and remove remediation roadblocks. We used the delivery-center approach to minimize use of the client space, reduce travel costs, and onboard resources in a short period of time. The project consisted of the following teams:

Our Process

LOB Support Team

Assisted in LOB/vendor production oversight by facilitating production meetings, generating daily production overviews customized to the needs of the group, communicating deadlines, and identifying and mitigating LOB-specific bottlenecks – all leading to increased productivity

Segmented each LOB’s customer population to strategically identify resources and timelines for remediating each sub-population

Trained LOB partners on tools, reporting, and processes that would be utilized after remediation, empowering them to complete future analysis and issue resolution

Served as the first escalation point (Tier I) for issues that could not be resolved by the LOB/vendor teams, researching and resolving issues if possible